The rules for qualifying by professional certification require maintaining good standing with the state licensure or registration requirements but do not requir

The rules for qualifying by professional certification require maintaining good standing with the state licensure or registration requirements but do not require actually practicing the profession covered by the certification, nor even having a minimum amount of work experience in that area. Very interesting. How does this apply to people who hold a Series 65 but do not practice as an investment adviser? In particular, Series 65 carries no requirement to be sponsored by a FINRA member firm, and many states don't require an investment adviser firm to register if there are fewer than 6 clients in that state. And New York, uniquely, does not require investment adviser representatives to register at all, though they do require that they either pass the exam or qualify for a waiver. So, if I move to NY (as I'm likely to do in 2021 or 2022 for unrelated reasons) and pass the Series 65 exam but don't practice as an investment adviser, do I automatically qualify as an accredited investor, either for a certain number of years since last passing the exam or indefinitely? If not, would it work to create and voluntarily register self-owned investment adviser firm (with as few as zero clients) and deal with the annual registration and financial statement paperwork? My guess is no and yes, respectively, possibly with a requirement to pass the exam every 2 years if my firm doesn't actually have any clients as would be required to truly count as practicing as an investment adviser. I see why they used the general securities representative example (Series 7) to illustrate their "you don't have to practice" requirement, since those lapse two years after leaving a qualifying firm, and the same therefore applies to accredited investor status on that basis. For Series 65, it is a lot murkier.